IR 05000335/1980021

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IE Insp Rept 50-335/80-21 on 800708-11.Noncompliance Noted: Inadequate Review & Approval of Fire Protection Base Sys Surveillance Insp Procedures
ML17209A181
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 08/01/1980
From: Conlon T, Miller W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17209A175 List:
References
50-335-80-21, NUDOCS 8010030094
Download: ML17209A181 (8)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I I 101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 AUG -0 tg8(I Report No. 50-335/80-21 Licensee:

Florida Power and Light Company 9250 West Flagler Street Miami, FL 33101

...Facility Name:

St. Lucie Docket No. 50-335 I,icense No. DPR-67 Approved b BVHHARY

. E. Conlon, Section Chief, RCES Branch Inspection on July 8-11, 1980 Areas Inspected Inspection at St. Lucie site near F rt

'erce, Florida Inspector:

W. H. Miller, Jr.

7 ~

p'G Date Si ned 5"o Date Signed This routine unannounced inspection involved 26 inspector-hours onsite in the areas of fire protection/prevention.

Results Of the areas inspected, one item of noncompliance was found (Infraction - Inade-quate review and approval of fire protection hose systems surveillance inspection procedures

- Paragraph 5.d.(5));

and, one apparent deviation was found (Devia-tion - Fire protection administrative procedures do not meet the NRC quidelines-Paragraph 5.c).

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DETAILS Persons Contacted Licensee Employees

  • C. M. Wethy, Plant Manager

+K. N. Harris, General Office C. Grozan, General Office - Licensing

>"G. A. Patrissi, General Office, Fire Protection-A. Anderson, QA

"N.

G. Roos, QC

<J. J. Walls, QC

>R. A. Wallace, Training - Operations

"-D. J. St. John, Training - Maintenence

<R. R. Jennings, Technical Staff T. Dillard, Maintenence Supervisor D. Wolf, ISC F. Gross, Mechanical Maintenance J. Lewis, Document Control Supervisor 2.

NRC Resident Inspector-S. A. Elrod-Attended exit interview Exit Interview The 'inspection scope and findings were summarized on July ll, 1980 with those persons indicated in Paragraph 1 above.

3.

Licensee Action on Previous Inspection Findings 4.

Not inspected.

Unresolved Items Unresolved items are matters about. which more information is required to determine whether they are acceptable or may involve noncompliance or devia-tions.

New unresolved items identified during this inspection are discussed in paragraph Nos. 5.a, 5.d.(2), 5.d.(4), 5.e and 5.f.

5.

Fire Protection Program The fire brigade organization and training, fire protection administrative control procedures, and surveillance inspection and test procedures for the plant fire protection systems were reviewe Fire Brigade Organization and Training Presently, there are two fire brigade organizations at St. Lucie.

One brigade is composed of eight employees from the maintenance department and the other brigade is composed of 17 employees from the plant oper-ating department and includes the watch engineer,'uxiliary equipment operator and nuclear turbine operator for each shift.

The maintenance fire brigade organization is the primary brigade during normal weekday working hours and operations personnel are responsible for implemehting the fire fighting procedures in the event of fire during other time periods.

The operations brigade is used to meet the three man fire brigade requirements of Technical Specification Section 6.2.2.f.

A review was made of the fire brigade organization and training which are described in Administrative Procedure 1800022, Fire Protection Program, and Emergency Procedure 3100025, Fire Emergencies.

These procedures and other plant policies do not address or do not. provide sufficient details to fully meet a number of the NRC fire protection guidelines of the document entitled,

"Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance".

Examples of areas in which the licensee's procedures do not adhere to the NRC quidelines are as follows:

(1)

Size of brigade appears inadequate to combate major plant fires as required by Paragraph 1.f.(4) of Attachment 1 to the NRC guidelines.

(2)

Qualifications of brigade members, including a physical examina-tion for performing strenuous activity, are not provided as required by Paragraph 2.b of Attachment 1 to the NRC guidelines.

(3)

Annual practice sessions for each brigade member are not a mandatory requirement as required by Paragraph 2 of Attachment 2 to the NRC quidelines.

(4)

Qualifications of fire brigade training instructors are not defined as required by Paragraph 1.b of Attachment 2 to the NRC guidelines.

(5)

Simulated use of fire fighting equipment in drills is not stipulated as required by Paragraph 3.c of Attachment 2 to the NRC guidelines.

(6)

Some drills are not specified to be conducted on backshift and unannounced as required by Paragraph 3.e of Attachment 2 to. the NRC guidelines.

(7)

Fire fighting strategies are not provided for safety-related areas of the plant as required by Paragraph d of the Attachment

to the NRC guideline The above items are examples of some of the fire,brigade training and organization features currently being evaluated by NRC (NRR).

This item is identified as Unresolved Item (335/80-21-01), fire brigade organization and training does not meet the NRC guidelines, and will be reviewed upon completion of the NRR evaluation."

A review was made of the fire brigade roster and training records. It was noted that the training of many brigade members was not up to date.

This problem was also noted during the licensee's 1980 fire protection audit (QAO-PSL-80-02-182)

and additional discrepancies were detected by a

QC inspector and identified by QC Report 7881, dated June 18, 1980.

This report is currently outstanding pending initi-ation of appropriate corrective action by the plant staff.

This item is identified as Unresolved Item (335/80-21-02), fire brigade training not up to date, and willbe reviewed during a subsequent NRC inspection.

b.

Offsite Fire Protection Forces This site is dependent upon the professional fire fighting forces of St. Lucie County and Fort Pierce Fire Departments.

On July 9-11, 1979, the plant provided training to 28 city/county fire fighters in the procedures for fighting fires in radiation area.

c

~

Fire Protection Administrative Control Procedures The licensee's fire protection procedures were reviewed to assure compliance with the NRC guidelines contained in document entitled

"Nuclear Plant Fire Protection Functional Responsibilities, Adminis-trative Controls and Quality Assurance",

as committed to by the licensee in letter L-78-280 from Robert E. Uhrig of FPM to V. Stello of NRC/NRR dated August 28, 1978.

The following discrepancies were noted:

(1)

Procedures are not provided for the control of open flame and other possible ignition sources other than welding and cutting operations as required by Paragraph 1 of Attachment 4 to the NRC guidelines.

(2)

Procedures do not require concurrence by a qualifed member of the plant's management or QC inspector when either supervisor or fore-man determines that a fire watch is not required for a welding, cutting or other hot work operation as required by Paragraph 2.c of Attachment 4 to the NRC quidelines.

(3)

Procedures do not require oxyacetylene equipment to be checked for leaks prior to being moved in to the work area as required Qy Paragraph 2.b.(4).of Attachment 4 to the NRC guidelines.

The above discrepancies are considered a failure to meet a commitment to the NRC and are identified as Deviation Item (335/80-21-03), fire protection administrative procedures do not meet the NRC guideline d.

Fire Protection Systems The following fire protection systems surveillance inspection and test procedures and recorded test data were reviewed and discrepancies noted:

Operating Procedure 1800050 - Fire System Periodic Test Recorded test data from January 1979 through June 1980 were reviewed and no discrepancies were noted.

(2)

Operation Procedure 1800051 - Semi-Annual Testing of Fire Detectors Recorded test data from June 1979 through April 1980 (3 inspec-tions)

were reviewed and no discrepancies were noted.

However, the licensee is currently only testing the minimum number of fire detectors per zone that is required to be operational without establishing the limiting condition of operation provisions of the Technical Specifications.

Section 8-3.1.5 of the National Fire Protection Associations Standard No.

72E (NFPA-72E) requires all smoke detectors to be tested semi-annually in accordance with the manufacturers instructions This item is identified as Unre-solved Item (335/80-21-04),

frequency of testing fire detection systems, pending further evaluation by the NRC/NRR.

(3)

Operating Procedure 1800053-Fire Protection System Annual Tests During the July 27, 1979 flushing test of the exterior water supply distribution system, the licensee noted that an approved flushing procedure was not provided.

Procedure 1800053 was revised to include this item and was approved by the Plant Manager on October 3, 1979.

The system flush required by Section 4.7.1l.l.e of the Technical Specifications is currently due and is to be accomplished using this revised procedure.

Full flow operational test data for the fire pumps dated August 7, 1979 and August 1, 1978 were reviewed and no discrepancies noted.

(4)

Maintenance Procedure - 1800054 - Fire Ba'rrier 18 Month Inspection Inspection report dated November 30, 1979 was reviewed and no discrepancies noted.

However, this procedure as well as Section 3/4.7.12 of the Technical Specifications only require an inspec" tion and verification of electrical penetrations.

The integrity of other types of penetrations such as doors, mechanical ducts, piping, etc.,

are not required to be verified.

This item is, identified as Inspector Followup Item (335/80-21-05), fire barrier penetrations requirements of Technical Specifications, pending further review by NR (5)

Plant Maintenance Instruction PVO PSL MM 1850-1-Fire Hose Stations Inspection The inspection records from Jamuary ll, 1979 through March 23, 1980 were reviewed.

The only discrepancy noted was the inspection interval between the February 5,1980 and March 23, 1980 inspection which exceeded the limits permited by the Technical Specifications.

This item had been identified by the licensee and reported to the NRC as reportable occurrence 335-80-6 and was attributed to the heavy work load while preparing for a scheduled refueling outage.

The inspections of the fire hose stations are accomplished under a written procedure which has been reviewed by the maintenance supervisor.

Section 6.8.1 of the Technical Specifications requires written procedures to be established, implemented and maintained covering the following: applicable procedures in Appendix "A" of Regulatory Guide 1.33; surveillance and test activities of Safety Related equipment; and, fire protection program implementation.

Section 6.8 '

of the Technical Specification requires these written procedures to be reviewed by the plant facility review group and approved by the Plant Manager.

The failure to follow this Technical Specifications requirement is identified as Non-compliance (Infraction) Item (335/80-21-05),

inadequate review and approval of fire protection hose system surveillance and test procedures.

The existing maintenance instruction is also inade-quate in that sufficient detail inspection and acceptance require-ments are not provided to assure that a high quality inspection will be accomplished.

This is considered a part of this noncom-pliance.

Audits The licensee's Audit Report QAO-PSL-80-02-183 of March 6, 1980 listed 3 discrepancies and 20 items classified as

"Areas of Improvement".

The

"Area of Improvement" items appear to have been mislabled and should have been identified as deficiencies.

The plant staff had initiated corrective action on the 3 discrepancies, but evidence was not available at the site to indicate the action taken to correct the 20 "Area of Improvement" items.

These items are in the area of general industrial fire prevention, such as the inspection and test of fire hose and fire brigade equipment, needed repairs and maintenance to fire protection sy'stems and the safe use and handling of flammable and hazardous materials.

During subsequent telephone discussions between the licensee and the inspector on July 16, 1980, the licensee advised that each of these items were being reviewed by the plant staff for appropriate corrective action.

This item is identified as Unresolved Item (335/80-21-06),

review of corrective action taken on 1980 fire'rotection audit deficiencies, and willbe reviewed during a subsequent NRC inspectio Fire Protection Quality Assurance Program A review of the records, correspondence, etc.,

between NRC and the licensee indicates that there is apparently no commitment by the licensee to include the fire protection program, under the existing plant quality assurance (QA) program or to provide a separate fire protection QA program.

This item is identified as Unresolved Item (335/80-21-08),

inadequate fire protection QA program, pending 'further review by the NRC.

/

g.,

Facility Tour A tour was made of the cable spreading room, control room, portions of auxiliary building and diesel generator building.

No discrepancies were noted on the fire protection features for these areas, except the floor hatch cover separating the cable spreading area from the lower floors was not in place on July 10; however, this hatch was replace prior to the conclusion of the inspection on July ll.

This was not a fire protection violation since the adequacy of the existing plant fire barriers is currently under review by the licensee and NRR.

Except as noted above, within the areas examined, no additional items of noncompliance or deviations were identifie l t